Raymond D. Jackson v. Duncan A. McIntosh; David Victorino
90 F.3d 330 (1996)
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Rule of Law:
Prison officials are not entitled to qualified immunity at the summary judgment stage for denying a specific medical treatment if the prisoner alleges facts indicating the denial was based on personal animosity rather than professional medical judgment. Such allegations create a triable issue of fact as to whether the officials were deliberately indifferent to a serious medical need, which is a clearly established Eighth Amendment right.
Facts:
- Raymond D. Jackson was a state prisoner suffering from a kidney condition that required him to be on dialysis.
- Dr. Duncan McIntosh and Dr. David Victorino were Jackson's treating physicians in prison.
- The doctors refused to provide Jackson with a kidney transplant.
- Jackson alleged that the doctors' refusal was not based on a valid medical judgment but was motivated by personal animosity towards him.
Procedural Posture:
- Raymond D. Jackson filed a lawsuit in federal district court against Dr. McIntosh and Dr. Victorino under 42 U.S.C. § 1983.
- The doctors (defendants) moved for summary judgment, arguing they were protected by qualified immunity.
- The district court (trial court) denied the doctors' motion for summary judgment.
- The doctors (appellants) filed an interlocutory appeal to the U.S. Court of Appeals for the Ninth Circuit to challenge the denial of their motion.
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Issue:
Are prison doctors entitled to qualified immunity on an interlocutory appeal from a denial of summary judgment when they deny a prisoner a specific medical treatment, and the prisoner alleges the denial was based on personal animosity rather than a difference of medical opinion?
Opinions:
Majority - Noonan, Circuit Judge
No. The doctors are not entitled to qualified immunity at this stage because the right to be free from deliberate indifference to serious medical needs is clearly established, and the prisoner has raised a genuine issue of material fact as to the doctors' motives. The court held that the constitutional right at issue is not a narrow 'right to a kidney transplant' but the broader, clearly established Eighth Amendment right to be free from deliberate indifference to serious medical needs, established in Estelle v. Gamble. While a mere difference of medical opinion regarding treatment is insufficient to show deliberate indifference, Jackson alleged the doctors denied him care based on personal animosity, not medical judgment. This allegation creates a triable issue of fact as to whether the doctors acted with conscious disregard to a risk to Jackson's health. Under the Supreme Court's ruling in Johnson v. Jones, a court of appeals lacks jurisdiction on an interlocutory appeal to review a district court's determination that a genuine issue of material fact exists. Therefore, because the district court found a triable issue as to the doctors' deliberate indifference, the appeal must be dismissed.
Analysis:
This decision reinforces the principle that qualified immunity protects officials from liability for reasonable errors in judgment, not from conduct motivated by malice or personal animosity. By focusing on the broader constitutional principle of 'deliberate indifference' rather than the specific act of 'denying a transplant,' the court prevents officials from escaping liability by framing the right at issue in an overly narrow, fact-specific way. The case also highlights the jurisdictional limits of interlocutory appeals regarding qualified immunity; appellate courts can decide the purely legal question of whether a right was clearly established, but they cannot review a trial court's finding that a genuine factual dispute exists for trial.
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